# ENABLE GAS TRANSMISSION, LLC — Warning Letter

**Citation:** CPF 220071012W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-06-06

CLOSED warning letter citing 192.805(a).

## Document text

Warning Letter involving ENABLE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.805(a). The case was opened on 2007-06-06 and is reported as closed as of 2007-06-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220071012W_warning letter_06062007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071012W/220071012W_warning%20letter_06062007.pdf

220071012w_warning letter_06062007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071012W/220071012w_warning%20letter_06062007_text.pdf

220071012w_warning letter_06062007_text.pdf

U 5 Department
oi Transportation
Pipeline and
Hazardous Materials Safettr
Administration
233 Peachtree Street Ste 600
Aiiahta, GA 30303
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
June 6, 2007
Mr Walter Ferguson
Sr Vice President and Chief Operatmg Officer
Centerpoint Energy Gas Transnussion
1111 Loissian, Suite 1120
Houston, TX 77002
CPF 2-2007-1012W
Dear Mr Ferguson
Between August 21, 2006 and November 3, 2006, a representanve of the Pipehne and
Hazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United
States Code inspected your Centerpoint Energy Gas Transmission pipeline facilities and
records in the Malvern, Russellville, and Carhsle Team areas in Arkansas
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulanons, Title 49, Code of Federal Regulations The item inspected and the
probable violation are
tl192. 805 Qualification program.
Each operator shall have and follow a written quahfication program. The
program shall include provisions to:
(a) Identify covered tasks. . .
Your wntten operator quahfication program (OQ program) is not adequate in that an
activity bemg performed by maintenance employees that meets the four part test
requirements of $192 801(b)(1-4) has not been identified as a covered task



The activity of conducting performance tests on compressor station gas detection and
alarm systems required of $192 736(c) is not included in your DOT Operator
Quahficarion Acnvines Summary document, which hsts the covered tasks included in
your OQ program This activity meets the four part test in that it (I) is performed on a
pipeline facihty, (2) is an operations or mamtenance task, (3) is performed as a
requirement of this part, and (4) affects the operation or integrity of the pipehne
PHMSA understands that the referenced activity is included m your Mechanical Skill
Level quahfication program, and that it is to be added to your OQ program later tlus
year
Under 49 United States Code, f 60122, you are sub) ect to a civil penalty not to exceed
$100, 000 for each violation for each day the violation persists up to a maxunum of $1, 000, 000
for any related series of violations We have reviewed the circumstances and supportmg
documents involved in this case, and have decided not to conduct additional enforcement action
or penalty assessment proceechngs at this time We advise you to correct the item(s) identifie
in this letter Fadure to do so will result in Centerpoint Energy Gas Transmission being sub)ect
to additional enforcement action
No reply to this letter is required If you choose to reply, in your correspondence please refer to
CPF 2-2007-1012W. Be advised that all matenal you submit in response to this enforcement
action is sublect to being made pubhcly avadable If you beheve that any portion of your
responsive material quahfies for confidential ueatment under 5 U S C 552(b), along with the
complete onginal document you must provide a second copy of the document with the portions
you believe quahfy for confidential treatment redacted and an explanation of why you beheve
the redacted information qualifies for confidential treatment under 5 U S C 552(b)
Linda Daugherty
Director, Southern Region
Pipeline and Hazardous Matenals Safety Administration
Enclosure Response Opnons for Pipehne Operators m Comphance Proceedmgs

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/220071012W>
- Source ID: `phmsa-enforcement`
- SHA-256: `c76671247fb2dfe29e1c268fac6fc2b572e721c71082e3be630e6b1289cdd553`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T17:35:34.819Z
- Document slug: `phmsa-enforcement-220071012w`

### Source metadata

```json
{
  "cpf": "220071012W",
  "operator": "ENABLE GAS TRANSMISSION, LLC",
  "region": "Southern",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.805(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "220071012W_warning letter_06062007.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/220071012W/220071012W_warning%20letter_06062007.pdf",
      "bytes": 60559,
      "category": "agency_document"
    },
    {
      "name": "220071012w_warning letter_06062007_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/220071012W/220071012w_warning%20letter_06062007_text.pdf",
      "bytes": 65556,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "ENABLE GAS TRANSMISSION, LLC"
}
```
